What we handle
Every case is different. We evaluate every resolution option available under current tax law and pursue the best possible outcome for your specific situation. All services are handled personally by Tim Wooten.
An Offer in Compromise allows eligible taxpayers to settle their entire IRS tax debt for less than the full amount owed. The IRS accepts offers when the amount offered represents the most they can reasonably expect to collect given your income, expenses, and assets. This program is powerful — but it is also complex, and not everyone qualifies.
National tax companies that guarantee OIC acceptance are misleading you. No one can guarantee IRS acceptance. What we guarantee is an honest evaluation of whether you qualify, and aggressive representation if you do. We also evaluate every other resolution option simultaneously — including Partial Pay Installment Agreements and equity payoff scenarios — to make sure the OIC is truly your best path before we pursue it.
A Partial Pay Installment Agreement is a monthly payment plan where you pay less than the full amount owed — and the remaining balance expires when the IRS collection statute runs out. Unlike a full installment agreement, PPIA payments are based on what you can actually afford.
Unlike an Offer in Compromise, there is no lump sum required upfront. For some clients this is actually a better outcome than an OIC — you pay nothing beyond your monthly ability, and the rest legally disappears over time.
An installment agreement is a structured monthly payment plan that brings you into compliance with the IRS and stops enforced collection action. Once an installment agreement is in place, the IRS cannot levy your wages or bank accounts as long as you remain current.
There are several types — streamlined, non-streamlined, and in-business trust fund — and the right structure depends on how much you owe, your financial situation, and whether the debt is personal or business. We handle every type and negotiate the terms that work for your budget.
Currently Not Collectible status is a formal IRS determination that you cannot pay your tax debt without compromising your ability to cover basic living expenses. When granted, the IRS halts all collection activity — no levies, no garnishments, no liens — while your financial hardship continues.
CNC is not permanent and does not eliminate the debt, but it stops the IRS clock and buys time. Combined with a collection statute analysis, CNC can be part of a strategy where the debt ultimately expires without full payment.
The IRS assesses penalties on top of tax debt — failure to file, failure to pay, accuracy-related penalties — and they add up fast. Penalty abatement is the formal process of requesting the IRS reduce or eliminate these penalties.
First-time abatement is available to taxpayers with a clean prior compliance history and is one of the most underutilized programs in the tax code. Reasonable cause abatement applies when circumstances beyond your control caused the non-compliance. We evaluate both and pursue every available penalty reduction before finalizing any resolution.
The Trust Fund Recovery Penalty is the IRS's most powerful collection tool against individuals. When a business fails to remit payroll taxes, the IRS can hold responsible individuals — officers, owners, bookkeepers — personally liable for the employee portion of those taxes. TFRP assessments can reach into the hundreds of thousands of dollars and follow you personally even after the business closes.
Defense requires a rapid, thorough investigation of who was actually responsible for collecting and paying the taxes, and aggressive challenge of the IRS's determination. This is one of the most consequential tax matters an individual can face — and one where attorney representation is not optional.
When a joint tax return results in a liability, the IRS can pursue both spouses for the full amount — even if one spouse had no knowledge of the problem and no involvement in the finances. Innocent spouse relief separates your liability from your spouse's, releasing you from responsibility for taxes you did not know about and did not benefit from.
There are three forms of relief — innocent spouse, separation of liability, and equitable relief — and each has specific requirements. Timing is critical: there are strict deadlines for filing innocent spouse claims.
When the IRS issues a Final Notice of Intent to Levy or a Notice of Federal Tax Lien, you have the right to request a Collection Due Process hearing — but the window is only 30 days. A CDP hearing stops the IRS from levying while the hearing is pending and gives you the right to challenge the appropriateness of the collection action, propose alternative resolutions, and — if the hearing officer rules against you — appeal to Tax Court.
CDP rights are among the most valuable protections available to taxpayers. Missing the 30-day window forfeits those rights permanently.
An IRS audit is not a conversation — it is an adversarial examination designed to identify additional tax, penalties, and interest. Representing yourself in an audit means the IRS agent is the only professional in the room. Attorney representation changes that dynamic immediately.
We handle all communications with the IRS examiner, respond to document requests, challenge improper adjustments, and — if necessary — take the matter to Appeals or Tax Court. We handle correspondence audits, office audits, and field audits for individuals and businesses.
Failing to file tax returns does not make the problem disappear — it makes it worse. The IRS will eventually file a Substitute for Return on your behalf using the information they have, with no deductions, no exemptions, and the highest applicable tax rate. The resulting balance is almost always higher than what you would actually owe if you filed properly.
We prepare and file all missing returns, negotiate any resulting balance, and get you back into compliance so the IRS has no grounds to pursue criminal charges for willful non-filing. In many cases, filing the missing returns dramatically reduces the balance.
The difference that matters
When the IRS won't accept a reasonable resolution, most enrolled agents and CPAs have no options left. Tim Wooten does — he can take your case to court.
Everything you share with us is protected. Enrolled agents and CPAs cannot offer this legal protection.
When you hire Gower, Wooten & Darneille, LLC, Tim Wooten is your attorney from the first call to the day your case closes. No hand-offs. No surprises.
Federal tax law is our focus. We represent clients with IRS problems across the entire country.
Ready to take the first step?
Confidential case evaluation — no pressure, no obligation. Tim Wooten will personally review your situation.
Gower, Wooten & Darneille, LLC · 4200 Northside Parkway NW, Building 12, Atlanta, Georgia 30327